State of Tennessee v. William Harold Smith, Alias, E2016-02137-CCA-R3-CD

Defendant William Harold Smith was convicted of failure to appear after a jury trial in Knox County and sentenced to three years with 35% release eligibility.
On appeal, the conviction was challenged as unsupported by sufficient evidence that the defendant knowingly failed to appear.
The underlying case involved a June 2015 theft charge and a July 29, 2015 general sessions court appearance that the defendant purportedly did not attend.
A Forfeiture of Bond and Conditional Judgment and an Attachment Upon Forfeiture were issued for the July 29, 2015 date.
The trial court later acquitted the defendant of theft and convicted him of failure to appear; the appellate court reversed and dismissed the failure to appear charge.
The court held that the State failed to prove beyond a reasonable doubt that the defendant knowingly failed to appear.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the evidence proves knowingly failing to appear	Smith	Smith challenges sufficiency; lack of explicit notice to appear.	Yes; insufficient evidence that Smith knowingly missed the date.
Whether the case-setting documents show knowledge of the July 29 date	State	Documents do not show explicit notice or typical procedure of informing defendants.	Yes; case setting alone insufficient to prove knowledge.

State v. Bland, 958 S.W.2d 651 (Tenn. 1997) (presumption of innocence governs sufficiency review; jury verdict requires strong evidence)
State v. Dorantes, 331 S.W.3d 370 (Tenn. 2011) (Jackson standard for sufficiency of the evidence applied to circumstantial/direct evidence)
State v. Vasques, 221 S.W.3d 514 (Tenn. 2007) (establishes standard for evidentiary inferences in sufficiency review)
State v. Tuggle, 639 S.W.2d 913 (Tenn. 1982) (reaffirms burden on State and standard for sufficiency analysis)